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Guide

Certified cost or pricing data,
and the 2026 threshold change

Formerly known as TINA, this is the requirement to disclose and certify cost or pricing data on higher value negotiated awards. The threshold moved substantially in 2026, and it reaches your subcontracts as well as your prime work.

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Threshold raised to $10MApplies to subcontracts too

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TINAstill

Thresholds moved; purchasing still owns the file

New thresholds for contracts after 30 June 2026

Certified data reaches your subcontracts

Current at price agreement is the usual failure

ON THIS PAGE

01What changed and when 02Why this is a purchasing question 03What certification asserts 04Handling this in purchasing

DIRECT ANSWERChecked August 2026

The Truthful Cost or Pricing Data statute, long known as TINA, requires contractors to submit and certify cost or pricing data on certain negotiated awards above a threshold. For contracts entered into after 30 June 2026 that threshold rose from $2.5 million to $10 million. Certifying data that is not accurate, complete and current creates defective pricing exposure.

What changed and when

The thresholds before and after

Sections 1804 and 1806 of the FY2026 National Defense Authorization Act revised these figures. The change is forward looking and does not alter awards already made.

Guides • Walkthrough

The thresholds before and after

Sections 1804 and 1806 of the FY2026 National Defense Authorization Act revised these figures. The change is forward looking and does not alter awards already made.

Certified data threshold now $10 million
CAS applicability raised to $35 million
Change applies after 30 June 2026

FY2026 NDAABEFORE / AFTER

≤ 30 JUN 26AFTER

Certified data$2.5M$10M

CAS applicability$2.5M$35M

Full CAS coverage$50M$100M

Forward looking only

Awards already made keep the earlier thresholds.

SECTIONS 1804/06

	Contracts entered into on or before 30 June 2026	Contracts entered into after 30 June 2026
Certified cost or pricing data threshold	$2.5 million	$10 million
Contract level CAS applicability	$2.5 million	$35 million
Full CAS coverage	$50 million	$100 million
Trigger contract mechanism	$7.5 million	Removed

Why this is a purchasing question

It reaches your subcontracts

Teams treat certified cost or pricing data as an accounting obligation attaching to their prime work. It also attaches to what they buy.

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Guides • Walkthrough

It reaches your subcontracts

Teams treat certified cost or pricing data as an accounting obligation attaching to their prime work. It also attaches to what they buy.

Accurate, complete and current at agreement
Applies award by award to subcontracts
Current is the element that fails most often

CERTIFICATION · SUBCONTRACT

Accurate · Complete · Current

PURCHASING

Accurate

Facts as they are, not as hoped

Complete

Nothing relevant left out

Current

Up to date at price agreement — fails most often

USUAL GAP

It attaches to what you buy, not only to prime accounting.

The challenge

Treated as accounting

The requirement is owned by finance, applied to prime proposals, and subcontract pricing is assumed to be somebody else's concern.

OwnerFinance

Applied toPrime work

SubcontractsOverlooked

With ProcureAudit

Shared with purchasing

Where a subcontract crosses the threshold, obtaining and analysing the data is a purchasing responsibility and the evidence belongs in the purchase file.

OwnerShared

Applied toBoth

SubcontractsCovered

The challenge

Data gathered early

Information is accurate when collected but superseded before price agreement, and nobody updates it, which is the most common defective pricing failure.

Accurate when gatheredYes

Current at agreementNo

ExposureReal

With ProcureAudit

Updated to agreement

Data is refreshed up to the point of price agreement, because that is the moment the certification speaks to.

Accurate when gatheredYes

Current at agreementYes

ExposureManaged

The challenge

Assumed

An exemption is relied on without the basis being recorded, so the file cannot show why data was not obtained.

ClaimedYes

DocumentedNo

DefensibleWeakly

With ProcureAudit

Documented

Where an exemption applies, the basis is recorded on the award so the absence of certified data is explained rather than unexplained.

ClaimedYes

DocumentedYes

DefensibleFully

The challenge

Obtained but not examined

Cost data is collected because it was required and filed without evidence that anybody analysed it, which defeats the purpose.

ObtainedYes

AnalysedNot shown

ValueLost

With ProcureAudit

Obtained and analysed

The data is examined, the analysis is recorded, and the file shows how it informed the negotiated price.

ObtainedYes

AnalysedShown

ValueRealised

What certification actually asserts

Three words that carry the exposure

Word	What it means in practice
Accurate	The data reflects the facts as they are, not as they were estimated or hoped to be
Complete	Nothing relevant has been left out, including information that would weaken your position
Current	The data is up to date as at the point of price agreement, which is the most commonly failed element because information gathered early is often superseded before agreement

Thresholds and exemptions in this area changed materially in 2026 and are subject to further rulemaking. Confirm the position for the specific award before relying on a figure.

Handling this in purchasing

Four things worth doing

Check the threshold per subcontract

The determination is made award by award, and the applicable figure now depends on when the contract was entered into.

Learn more

Refresh data up to agreement

Current means current at price agreement. Data gathered early and never updated is the most common failure.

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Record the exemption basis

Where certified data was not required, the file should say why rather than simply containing nothing.

Learn more

Show the analysis

Data obtained and filed without evidence of analysis satisfies the form of the requirement and none of its purpose.

Learn more

FAQ

Common questions about certified cost or pricing data

What is TINA?

The Truth in Negotiations Act, now referred to as the Truthful Cost or Pricing Data statute. It requires contractors to submit and certify cost or pricing data on certain negotiated awards above a threshold.

What is the current threshold?

For contracts entered into after 30 June 2026 it is $10 million, raised from $2.5 million by the FY2026 National Defense Authorization Act. Contracts entered into on or before that date keep the earlier threshold.

Does this apply to subcontracts?

Yes, which is often overlooked. Where a subcontract crosses the threshold, obtaining and analysing the data is a purchasing responsibility and the evidence belongs in the purchase file.

What does defective pricing mean?

That certified data was not accurate, complete or current. Consequences can include a reduction in contract price and, where knowledge is involved, considerably more serious exposure.

Which element fails most often?

Current. Data is gathered accurately, then superseded by newer information before price agreement, and nobody updates the submission. The certification speaks to the position at agreement.

Are there exemptions?

Yes, including for commercial products and services, where adequate price competition exists, and where prices are set by law or regulation. Where you rely on one, record the basis on the award.

Did the CAS thresholds change at the same time?

Yes. The same legislation raised the contract level CAS applicability threshold to $35 million and full coverage to $100 million for contracts entered into after 30 June 2026.